According to the indictment, Vargas was the President of Attorney’s Printing Supply (APS), a printing business located at 120 2nd Street in San Francisco. APS supplied printing services and supplies to law firms in Northern California. Tashiro was employed as a purchasing specialist with Wilson, Sonsini Goodrich & Rosati (WSGR) a law firm headquartered in Palo Alto, Calif. Dominguez was the accounting manager for APS. APS supplied WSGR with stationary, envelopes, business cards and other office supplies.

The indictment states that from September 2002 through November 2006, Tashiro conspired with Vargas and Dominguez to submit fraudulent orders for tab dividers to APS. APS billed WSGR for the fraudulent orders as if those tab dividers had in fact been delivered. The total amount that WSGR overpaid APS for the tab dividers that were never ordered nor delivered was approximately $1 million.

Vargas, Tashiro and Dominguez are scheduled to make their initial appearance in federal court in San Jose on Oct. 8, at 9:30 a.m., before United States Magistrate Judge Patricia V. Trumbull.

The maximum statutory penalty for each count of conspiracy in violation of 18 U.S.C. § 371 is five years imprisonment and a fine of $250,000 or twice the gross gain or loss from the offense, and restitution. The maximum statutory penalty for each count of mail and wire fraud in violation of 18 U.S.C. § 1341 and 1343 is 20 years imprisonment and a fine of $250,000, or twice the gross gain or loss, and restitution. The maximum penalty for conspiracy to commit money laundering in violation of 18 U.S.C. § 1956(h) is 10 years imprisonment and a fine of $250,000, or twice the gross gain or loss, and restitution. However, any sentence following conviction would be imposed by the court after consideration of the U.S. Sentencing Guidelines and the federal statute governing the imposition of a sentence, 18 U.S.C. § 3553.